The ACA paper filing deadline has passed. What can you do now?

If you’re an applicable large employer (ALE) that hasn’t yet filed your 1094/1095-C and 1094/1095-B forms with the IRS, and your plan is to paper file, we have some bad news for you. The deadline for Affordable Care Act (ACA) paper filing was Feb. 28, 2019. Your time has run out.

If your forms weren’t postmarked by the 28th, then you officially missed the mark. This is a problem.

Now that the IRS has decided to give additional penalties to employers that didn’t issue 1095-C forms to their employees on time or missed the filing deadline for 1094-C and 1095-C forms, it’s even more costly to miss the filing deadline.

Fortunately, there are still steps you can take to avoid pesky fines. Let us explain.

Take advantage of your extension

The IRS isn’t going to accept forms sent after the paper filing deadline.

However, there is one exception: If you applied for a filing extension. The catch is that you had to apply for the extension prior to the actual filing deadline.

If you had enough foresight to apply for an extension before the paper filing deadline, you don't have to worry. But extensions are only for people who realized they needed one beforehand.

If you missed the deadline, this is no longer an option.

Choose to file electronically at a later date

Just because you missed the paper filing deadline doesn’t mean you missed all available ACA deadlines. There’s always the option to file electronically, as that deadline isn’t until April 1, 2019.

Word to the wise: Don’t wait until the last minute to e-file – especially if you’re planning to do so without a third-party filer.

While the forms for paper and e-filing are exactly the same, the latter involves a lot of technical guidelines. And in order to file accurately, the IRS requires that you follow them.

First, you’re placed in a testing system. There, you create sample forms, which you then fill out using listed scenarios provided by the IRS. This “sample filing” is how you prove to the IRS that you can file accurately and meet its standards.

There’s no timeline for the sample filing. You submit the forms, and the IRS provides feedback. You continue to submit the forms until the IRS deems they are correct. Once this happens, the IRS clears you into its production system.

You have to repeat these steps every year.

Now what?

If you have more than 250 forms to file, don’t worry that the paper filing deadline has passed: You must e-file. If you’re filing fewer than 250 forms, you could have used paper filing. For companies that only need to file 20 to 40 forms, for example, it might have been easier to just paper file.

That being said, the deadline for paper filing has gone by. If that’s the route you wanted to take, hopefully you’ve already submitted the forms. Missing the deadline isn’t exactly the end of the world. But your available options after the fact are limited.